Draft White Paper 

REVIEW OF THE USE OF SURROGATE DATA FOR ESTIMATING
 

INTAKES OF URANIUM AT GENERAL STEEL INDUSTRIES 

Contract Number 200-2009-28555 

Prepared by 

Robert Anigstein 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

July 16, 2012 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted. 
 

 

 

 

 

 

 

 

 

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S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

Document Description: 

White Paper: Review of the Use 

of Surrogate Data for Estimating 

Intakes of Uranium at GSI 

NIOSH Dose Reconstruction Program Effective Date: 

Draft – July 16, 2012 

Revision No. 0 (Draft) 

REVIEW OF THE USE OF SURROGATE DATA 

FOR ESTIMATING INTAKES OF URANIUM AT 

GENERAL STEEL INDUSTRIES 

Page 2 of 22 

Task Manager: 

____________________________ Date:__________ 

Robert Anigstein, PhD 

Supersedes: 

N/A 

Project Manager: 

____________________________ Date:__________ 

John Stiver, MS, CHP 

Reviewers: 

John Mauro, PhD 

 William C. Thurber, MS 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 7/16/12 Initial issue 

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Review of the Use of Surrogate Data for Estimating Intakes of Uranium 

at General Steel Industries 

1 Background 

During Meeting 84 of the Advisory Board on Radiation and Worker Health, the Board tasked 

SC&A with reviewing NIOSH’s use of surrogate data for estimating intakes of uranium 

at General Steel Industries (GSI). In Appendix BB to TBD-6000, Allen and Glover (2007) based 

the activity concentrations of airborne uranium during uranium handling operations on that of a 

uranium slug production operator listed in the parent document (Allen 2011, Table 7.6).1 That 

table lists measured airborne uranium activity concentrations reported by Harris and Kingsley 

(1959). The measurements were taken at an unnamed plant or plants in the breathing zone of the 

die-processing technician who was involved in the fabrication of finished uranium shapes for 

reactor fuel elements, known as “slugs.”2 These measurements were performed during the 

processing of slugs produced by powder metallurgy, a process in which heated uranium powder 

is placed in a die and hot pressed into the desired shape. Harris and Kingsley list five operations 

performed by the die-processing technician, in order of decreasing breathing zone uranium 

concentrations—the highest concentration was measured during the stamping of the slug, which 

apparently refers to numbering the slug in a pneumatic numbering machine. 

2 Evaluation of the Use of Surrogate Data 

The ABRWH Work Group on Use of Surrogate Data (2010) issued five “criteria that need to be 

considered in determining whether the specific use of surrogate data for individual dose 

reconstruction is scientifically sound and appropriate for that particular application.” We have 

reviewed the use of the slug stamping operation as a surrogate for the uranium handling 

operations at GSI against these five criteria. Following the statement of each criterion is an 

evaluation of how well the use of these surrogate data conforms to that criterion. 

2.1 Criterion 1: Hierarchy of Data 

It should be assumed that the usual hierarchy of data would apply to dose 

reconstructions for that site (individual worker monitoring data followed by coworker data followed by workplace monitoring data such as area sampling 

followed by process and source term data). This hierarchy should be considered 

when evaluating the potential use of surrogate data. Surrogate data should only 

be used to replace data if the surrogate data have some distinct advantages over 

the available data and then only after the appropriate adjustments have been made 

to reflect the uncertainty inherent in this substitution [italics added for emphasis]. 

1

 The original reference was to the 2006 version of this document—the relevant values are unchanged. The 

cited value is listed in Table 7.6, not 7.8, as incorrectly cited by Allen and Glover (2007). 

2

 Harris and Kingsley (1959) acknowledge the cooperation of several individuals and five government-owned or 

private facilities involved in uranium fabrication. However, the authors do not indicate which facilities were the source of 

which data, or whether other, unnamed facilities were also involved. 

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2.1.1 Evaluation of Hierarchy of Data 

There are no monitoring data relating to uranium intakes at GSI. However, some process and 

source term data are available, namely information on the duration of uranium handling 

operations and some limited information on the nature of the uranium metal handled at GSI. 

Only the duration of the handling operations, based on the available MCW purchase orders, was 

utilized by Allen and Glover (2007) in their analysis. Murray and Brown (1994, Table 4) present 

surface contamination measurements at 32 random locations in the Old Betatron Building at GSI, 

performed in June 1993, prior to remediation under FUSRAP. These data could have been 

utilized in modeling surface contamination, as discussed in section 4 of the present report. 

Instead, Allen and Glover cite only the maximum measured contamination level reported in an 

earlier FUSRAP survey (Cottrell and Carrier 1990) and observe it is “reasonably close” to the 

value derived by their model. Thus, we conclude that the use of surrogate data does not strictly 

conform to the hierarchy of data. 

2.1.2 Evaluation of Appropriate Adjustments to Surrogate Data 

We next need to determine if appropriate adjustments have been made to the surrogate data as it 

was applied to GSI. The measured air concentrations corresponding to the five operations 

presented by Harris and Kingsley (1959) are listed in the first column of numerical values (Allen 

2011, Table 7.6), followed by the corresponding geometric means. According to Allen (2011): 

“If the air concentration was presented [by Harris and Kingsley (1959)] as a single value, this 

value was assumed to be the arithmetic mean, with an assumed geometric standard deviation 

(GSD) of 5.” The ratio μ:μg can be calculated using the following formula:3 

μ = arithmetic mean 

μg = geometric mean 

g = geometric standard deviation 

= 5 (Allen 2011) 

According to the above formula, = 3.65; however, the values of μ and μg listed by Allen 

(2011, Tables 7.2–7.7) yield  2.23. The values of μg listed by Allen are thus about 60% 

higher than the values calculated on the basis of the stated assumptions. Although this higher 

value is claimant favorable, it is not scientifically correct. 

Allen (2011, Table 7.6) listed the geometric mean of the operator’s daily weighted average 

(DWA) air concentration, which was calculated as 75% of the μg listed for the slug stamping 

operation. The factor of 75% was based on the assumption that the 25% of the operator’s time 

3

 Derived from Gilbert 1987. 

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was spent away from the area of high uranium concentrations. Allen and Glover (2007) adopted 

this value as the uranium airborne activity concentration at GSI during the time the workers were 

handling uranium before and after betatron radiography. 

Aside from the error in calculation, we question the use by Allen and Glover (2007) of an 

airborne uranium concentration derived by adjusting the Harris and Kingsley (1959) data. First, 

since the derived concentration was used as a fixed value that represented the average air 

concentrations during the relatively brief handling operations (assumed by Allen and Glover to 

last one hour at a time), it would be more appropriate to use the measured concentration 

presented by Harris and Kingsley and listed by Allen (2011, Table 7.6), rather than a derived 

geometric mean, which is appropriate for a lognormal distribution, but not for a fixed value. 

Second, the factor 75% may be appropriate for estimating the DWA exposure, averaged over an 

8-h workday, since the worker would occasionally be away from his work station. It should not 

be applied to the short-term exposures, since these exposure times are based on the time actually 

spent handling the uranium metal at GSI. Using the actual measured air concentration reported 

by Harris and Kingsley would lead to an increase of X2.9 over the value employed by Allen and 

Glover. 

We conclude that “appropriate adjustments” were not made to these surrogate data. We find that 

Criterion 1 is not fully satisfied by the use of the slug stamping scenario presented by Allen 

(2011). 

2.2 Criterion 2: Exclusivity Constraints 

[In situations where] there are no or very little monitoring data available . . . the 

use of the surrogate data as the basis for individual dose reconstruction would 

need to be stringently justified [italics added for emphasis]. This judgment needs 

to take into account not only the amount of surrogate data being relied on relative 

to data from the site but also the quality and completeness of that surrogate data.4 

As stated previously, there are no monitoring data on uranium intakes at GSI. Allen and Glover 

(2007) selected the scenario presented by Allen (2011) that listed the lowest uranium aerosol 

concentrations. The basis for the selection was their observation that the GSI uranium handling 

operations resulting in less disturbance of the metal than the other scenarios listed by Allen. We 

do not agree that the use of the surrogate data was stringently justified. We find that Criterion 2 

is not satisfied. 

2.3 Criterion 3: Site or Process Similarities 

One of the key criteria for judging the appropriateness of the use of surrogate data 

would be the similarities between the site (or sites) where the data were generated 

and the site where the surrogate data are being utilized. The application of any 

surrogate data to an individual dose reconstruction at a site should include a 

careful review of the rationale for utilizing that source of data. Factors that could 

4

 Only the relevant text from Criterion 2 is quoted here. 

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be considered include, but are not limited to, similarity of the production 

processes, presence or absence of conditions that might affect exposure, and 

monitoring methods employed at the site(s). The potential availability of other 

sources of surrogate data needs to be considered and the selection of the surrogate 

data used for dose reconstruction justified. Some of the questions to be 

considered where appropriate are: 

	 Are there other sources of surrogate data that were not used? 

	 Do these other potential sources contradict or undermine the application of the 

data from the selected site? 

	 Are there adequate data characterizing the site being used that would help 

support its application to other sites? 

	 Do the surrogate data reflect the type of operations and work practices in use 

at the facilities in question? 

Surrogate data should not be used if the equivalence of working conditions, 

source terms, and processes of the surrogate facility to the one for which dose 

reconstructions are being done cannot be established with reasonable scientific or 

technical certainty as outlined here. 

Our first observation regarding Criterion 3 is the dissimilarity of uranium slugs produced by 

powder metallurgy and the recast uranium ingots or “dingots” (ingots produced by direct 

reduction of UF4) at GSI. Not only were the uranium objects dissimilar, the stamping of 

numbers on the slugs bears no resemblance to setting up and transporting the uranium objects at 

GSI. 

We note that the NIOSH/DCAS Web site lists approximately 124 work sites for which DCAS 

has developed information. We believe that NIOSH should have performed a systematic review 

of those sites that handled uranium metal and at which concentrations of airborne and/or surficial 

uranium levels were recorded. Such a review could answer the question: Are there other 

sources of surrogate data that were not used? 

The third bullet under Criterion 3 asks: Are there adequate data characterizing the site being 

used that would help support its application to other sites? Although Harris and Kingsley (1959) 

describe the powder metallurgy operations involved in producing uranium slugs, the specific 

work site is not identified, and only sparse descriptions of the facilities at this site (or sites) are 

furnished. We conclude that there are not “adequate data characterizing the site.” Finally, in 

answer to the fourth bullet, we conclude that the surrogate data do not reflect the types of 

operations and work practices used at GSI. 

We find that the use of slug stamping as a surrogate for the handling of uranium at GSI does not 

fulfill Criterion 3. 

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2.4 Criterion 4: Temporal Considerations 

Consideration also needs to be given to the period in question, since working 

conditions and processes varied in different periods. Surrogate data should 

belong in the same general period as the period for which doses are sought to be 

reconstructed unless it can be demonstrated that the working conditions, 

procedures, monitoring methods, and (perhaps) legal requirements were 

comparable to the period in question. 

According to Rolfes et al. (2008): “[I]t is likely that the data [presented by Harris and Kingsley 

(1959)] were collected before 1957 and perhaps as early as the late 1940s.” We note that the 

report was submitted for publication on June 6, 1958. Thus, the measurement of uranium air 

concentration cited by Allen and Glover (2007) may have been made 10–20 years prior to the 

end of the period of AEC operations at GSI (1953 to mid-1966). Allen and Glover need to 

justify the application of this measurement to the entire period of operations at GSI. 

2.5 Criterion 5: Plausibility 

The manner in which the surrogate data are to be used must be “plausible” with 

regard to the reasonableness of the assumptions made. The plausibility 

determination should address issues of: 

	 Scientific plausibility. Are the assumed models (e.g., bioassay, concentration 

gradients) scientifically appropriate? Have the models been validated (where 

feasible) using actual monitoring data collected in a similar situation? 

	 Workplace plausibility. Are the assumed processes and procedures (including 

monitoring) plausible for the facility in question? Have all of the factors that 

could significantly impact exposure been taken into account? Is adequate 

information available about the facility in order to be able to make a fair 

assessment? 

2.5.1 Evaluation of Scientific Plausibility 

According to Allen and Glover (2007), uranium handling operations, derived from purchase 

orders issued by Mallinckrodt Chemical Works (MCW), had a maximum total duration of ~218 

h/y, out of an assumed work-year of 3,250 h. The remainder of the time, uranium intakes were 

based on resuspension of uranium from contaminated surfaces. (This was the sole source of 

internal exposure during the residual period.) Thus, the buildup of uranium on the floor is 

potentially significant in the assessment of uranium intakes by GSI workers. Allen and Glover 

assume that the uranium air concentration is achieved immediately at the beginning of the 

handling operation and disappears immediately after its end. The former might be a plausible 

and claimant-favorable bounding assumption, since it is difficult to estimate the time-dependence 

of the build-up of uranium dust in the vicinity of the uranium metal. However, the latter 

assumption, that the deposition abruptly stops at the end of the operation, is neither plausible nor 

claimant favorable. In reality, the dust would continue to be generated during the entire uranium 

handling period. It would settle to the floor during this period, and would continue to do so until 

the airborne concentration is depleted. The time required is determined by the elevation of the 

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dust above the floor and the deposition velocity. As an extreme example, the dust concentration 

could be assumed to extend from the floor to the roof, a height of 35 ft (10.7 m). Assuming a 

settling velocity of 7.5 × 10-4 m/s (Allen 2011), it would take almost 4 h for all the dust to settle 

to the floor. Thus, the assumption that the deposition abruptly stops at the end of the handling 

operation could significantly understate the surficial concentration. 

Aside from the question regarding the actual duration of deposition, and questions regarding the 

adjustments to the air concentration data reported by Harris and Kingsley (1959) that are 

discussed in section 2.1.2 of the present report, we question the plausibility of calculating the 

surficial concentration from deposition during the hours of uranium handling during one year— 

an arbitrarily chosen time period. The model assumes that the surficial contamination 

throughout a given calendar year has a constant value, derived from a steady deposition of 

uranium dust during the assumed hours of uranium handling during that year. There is no 

carryover of this accumulation from year to year—it is as if this contamination level existed at 

the beginning of the year (even before any uranium handling has taken place) and vanished at the 

end of the year, to be replaced by the accumulation from the next year’s uranium handling. The 

maximum hours of uranium handling were during the period July 1, 1961 to June 30, 1962. 

Allen and Glover (2007) assumed that the surficial contamination level from July 1, 1961, until 

the end of the residual period was equal to the total uranium deposition during that 12-month 

period, with no removal but also no contribution from deposition that occurred before or after 

that period. A more realistic model would assume continuous buildup of the surficial 

contamination, based on the periods of uranium handling operations, together with continuous or 

intermittent removal. The authors need to demonstrate that the assumed one-year period of 

accumulation is scientifically plausible. 

2.5.2 Evaluation of Workplace Plausibility 

The assumption that handling of uranium ingots at GSI had a potential for generating aerosols 

that were comparable to the uranium slug stamping operation reported by Harris and Kingsley 

(1959) does not meet the criterion of workplace plausibility. The assumption that the surficial 

contamination levels can be calculated from the airborne concentrations reported by Harris and 

Kingsley is likewise inconsistent with this criterion. Uranium oxide could have been removed 

from the surfaces of ingots or dingots by mechanical abrasion during the transport and 

positioning of the metal objects. The particles could range in size from fine aerosols to flakes as 

big as 1⁄4-inch in diameter. 

In its response to Issue 5 of SC&A (2009) findings on TBD-6000, NIOSH stated: “Large flakes 

of uranium that are produced would fairly quickly be ground into dust under foot and forklift 

traffic typical of operating area. They would then be available for resuspension and contribute to 

the air concentrations.” We agree that, over the long term, equilibrium would be achieved 

between the resuspendable surface layer and the uranium aerosols. According to Allen (2011), 

NIOSH assumed that 30 days were required to achieve such equilibrium, once fine particles were 

deposited on the floor. Assuming, for the sake of the present argument, the validity of the 

assumed equilibrium period, the settling velocity—based on an assumed AMAD (activity 

median aerodynamic diameter) of 5 μm—and some assumed persistent air concentration, it can 

be argued that the intermittent introduction of large flakes is reflected in the equilibrium air and 

surface concentrations. However, the assumed air concentrations, derived from the Harris and 

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Kingsley (1959) slug stamping scenario, do not correspond to equilibrium conditions, since such 

equilibria were not achieved during the intermittent uranium handling operations at GSI. We 

thus find that the calculation of surficial uranium concentrations described by Allen and Glover 

does not meet the criterion of workplace plausibility. 

2.6 Summary of Findings 

We find that the use of uranium air concentrations based on measured on measurements made 

during the stamping of uranium slugs as a surrogate for uranium air concentrations at GSI does 

not meet the five ABRWH criteria for the use of surrogate data. Our findings with respect to 

these criteria are summarized as follows: 

Criterion 1. Hierarchy of Data 

	 Data from the 1993 FUSRAP survey (Murray and Brown 1994), that could 

help estimate levels of contamination on the floor of the Old Betatron 

Building, were not utilized by NIOSH. 

	 Adjustments to the measurement reported by Kingsley and Harris (1959), 

described by Allen (2011) and utilized by Allen and Glover (2007), are not 

appropriate to the uranium handling scenario at GSI. 

Criterion 2. Exclusivity Constraints: The use of the surrogate data was not stringently 

justified. 

Criterion 3. Site or Process Similarities 

	 Neither the form of the uranium metal (slugs produced by powder metallurgy 

vs. recast ingots or direct reduced dingots), nor the processes (stamping 

numbers on slugs vs. transporting uranium objects and positioning them for 

radiography) are sufficiently similar to justify the use of the surrogate data. 

	 Alternate sources of surrogate data (e.g., the 124 work sites for which NIOSH 

has collected information) were not evaluated. 

	 There are insufficient data regarding the characteristics of the surrogate site to 

support the use of the surrogate data for GSI. 

Criterion 4. Temporal Considerations: The Kingsley and Harris (1959) data were 

most likely collected between the late 1940s and ca. 1957. The 

measurement used as a surrogate at GSI could thus precede the end of the 

covered the period by 10–20 years. The application of these data for the 

1953-1966 period of AEC operations needs to be justified by Allen and 

Glover (2007). 

Criterion 5. Plausibility 

	 The methodology of calculating surface contamination levels based on the 

assumed uranium aerosol concentration is not scientifically plausible. 

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 The assumption that the surface contamination levels result only from the 

deposition of aerosols during the uranium handling operations does not satisfy 

the criterion of workplace plausibility. 

3. Use of Alternate Scenarios 

We examined the possible use of surrogate data from five other uranium metal working scenarios 

described by Allen (2011). None of these operations satisfy the surrogate data criteria any better 

than the slug stamping scenario. 

We also examined the data in the report on uranium aerosol concentrations in the melt plant 

building at Hanford (Adley et al. 1952). Several operations involving the handling of uranium 

rods resemble the handling uranium operations at GSI more closely than the slug stamping 

scenario described by Allen (2011). Three operations that involve storage bay activities are 

listed below. 

U concentration Operation 

10-5 μg/cc* dpm/m3

** 

Unloading rods from truck with fork lift 258 3,926 

Receiving rods: unloading truck and stacking rods; 34 517 sample in breathing zone of man operating fork lift 

Loading straightened rods directly from table onto 5.8 88 truck; general atmosphere in storage bay 

Source: Adley et al. 1952, Table VII 

* Reported by Adley et al. 

** Calculated total activity of uranium isotopes in ratios of natural abundance 

To be consistent with the choice by Allen (2011, Table 7.6) of the maximum concentration 

produced by the uranium slug production, the first operation listed above should be selected to 

characterize this scenario. The corresponding activity concentration is more than 6 times higher 

than that reported for the slug stamping scenario by Harris and Kingsley (1959), and would 

consequently lead to dose assessments that are more claimant favorable. Although this operation 

better satisfies Criterion 3, Site or Process Similarities, and may satisfy Criterion 4, Temporal 

Considerations, additional study would be required to determine if other criteria are satisfied. In 

particular, we continue to have reservations about conformity with Criterion 5, Plausibility, 

which concern the model which NIOSH uses to calculate the surficial contamination levels, 

regardless of the choice of the aerosol concentration during the uranium handling operations. 

4. Recommendation 

SC&A recommends that NIOSH develop a methodology for estimating uranium intakes at GSI 

that does not rely on surrogate data. We suggest a model that uses the exponential source-term 

depletion rate recommended in OTIB-0070 (Sharfi 2012). The contamination levels on the floor 

of the Old Betatron Building at the time of the 1993 cleanup, reported by Murray and Brown 

(1994), together with the depletion rate and the varying hours of uranium handling operations at 

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GSI, could be used to calculate the average surficial uranium concentrations during each year of 

the operational and residual periods. 

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References 

ABRWH Work Group on Use of Surrogate Data, 2010. “Criteria for the Use of Surrogate Data,” 

Final Draft (May 14, 2010). http://www.cdc.gov/niosh/ocas/pdfs/abrwh/proc/abrwh-proc-sdr0.pdf. 

Adley, F. E., W. E. Gill, and R. H. Scott, 1952. “Study of Atmospheric Contamination in the 

Metal Melt Building,” HW-23352 (Rev.); SRDB Ref. ID: 27354. 

Allen, D., and S. Glover, 2007. “Site Profiles for Atomic Weapons Employers That Worked 

Uranium and Thorium Metals - Appendix BB: General Steel Industries,” Battelle-TBD-6000, 

Appendix BB, Rev. 0. http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r0.pdf. 

Allen, D., 2011. “Site Profile for Atomic Worker Employers that Worked Uranium Metals,” 

Battelle-TBD-6000 Rev. 1. http://www.cdc.gov/niosh/ocas/awedocs.html#b6000. 

Cottrell, W. D., and R. F. Carrier, 1990. “Results of the Radiological Survey at the Granite City 

Steel Facility, Granite City, Illinois,” ORNL/RASA-89/10. Oak Ridge, TN: Oak Ridge National 

Laboratory. 

Gilbert, R. O., 1987. Statistical Methods for Environmental Pollution Monitoring. New York: 

Van Nostrand Reinhold. 

Harris, W. B., and I. Kingsley, 1959. “The Industrial Hygiene of Uranium Fabrication,” A.M.A. 

Archives of Industrial Health, 19, 540–565. 

Murray, M. E., and K. S. Brown, 1994. “Results of the Independent Verification Survey at the 

Old Betatron Building, Granite City, Illinois (GSG001),” ORNL/RASA-94/2. Oak Ridge, TN: 

Oak Ridge National Laboratory. 

Rolfes, M., P. L. Lee, and C. W. Bloom, 2008. “Chapman Valve Manufacturing Company, 

Indian Orchard, Massachusetts,” ORAUT-TKBS-0033, Rev. 2. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/chapman-2.pdf. 

S. Cohen & Associates (SC&A), 2009. “Issue Resolution Matrix for SC&A Findings on TBD6000.” (October 14, 2009) 

Sharfi, M. M., 2012. “Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities,” ORAUT-OTIB-0070, Rev. 01. 

http://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t70-r1.pdf. 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker
 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.